Internet Transfers & MMDA Limitations
by Mary Beth Guard, BOL Guru
Question: I'm wondering if you would mind clarifying whether or not transfers made via the Internet should be considered as one of the limited number of withdrawals for a Money Market Account per regulation? It seems to me that it would be considered the same as an ATM transaction, however, our transfers via the internet are coded the same as a Telephone Transfer and are counted towards the number of allowed transactions.
Answer: Transfers made via the Internet take place using a phone line - whether it is a dial-up connection, an ISDN line, or DSL. They are therefore considered "covered transfers" and are counted toward the limit.
The types of transfers that are not counted are those made in person, by messenger, or at an ATM. What each of those has in common is that the customer (or his agent, the messenger), has to get up and go. Some people keep it all straight by thinking of it in terms of a "seat of the pants" rule. If the customer has to get up off the seat of his pants (or his agent does), the transfer is not counted. If he performs the transfer without getting up and going anywhere (via the Internet, by telephone, or by preauthorized transfer), it counts toward the limit.
[Editors Note: As of 7/2/09, the separate limit of three per month for checks, POS debit card transactions, etc., has been eliminated, and those transactions are now only subject to the 6/month limit that applies to other restricted transfers and withdrawals.]
The original version appeared in the October 2002 edition of the Oklahoma Bankers Association Compliance Informer.
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